Taking 30(b)(6) Corporate Representative Depositions in Personal Injury Cases

Dan Schiavetta | Russo & Gould LLP

Dan Schiavetta, of counsel to Russo & Gould LLP in New York City, has been a litigator for 30 years and is admitted in all New York and New Jersey state and federal courts and the Second and Third Circuit Courts of Appeals. For 20 years he defended the Catholic Church in sexual abuse cases and other matters. He also has wide experience in insurance coverage litigation, nursing home defense, and appellate practice. He is a 1992 graduate of the University of California, Davis School of Law where he was a law review editor and moot court judge. In his previous career as a social worker he was the director of a crisis center and 24-hour hotline. He is also the author of “The Supreme Court for Short Attention Spans: 2000 Tiny Case Summaries Too Short to Bore You”, available on Amazon.

I. Establishing knowledge and avoiding “apex deposition” rule | 2:00pm – 2:30pm

II. Developing normally ignored aspects of personal injury case | 2:30pm – 3:00pm

Break | 3:00pm – 3:10pm

III. Finding other witnesses, records, possible spoliation issues | 3:10pm – 3:40pm

IV. Dealing with protective orders and motions to quash, and privilege and “business judgment” objections | 3:40pm – 4:10pm